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Mentor Privacy Policy

Mentor Privacy Policy

Mentor’s Privacy Policy – Version 1 – Valid as of 25 May 2018

Mentor designs, develops, and manages the software InfoMentor. InfoMentor is a comprehensive information and education system for schools and other educational institutions. Mentor’s customer base is made up of roughly 1200 customers and our services include various consulting, customer service and hosting of independent websites. The company operates in five different countries; Sweden, England, Switzerland, Germany, and Iceland where its headquarter are located.

InfoMentor makes life easier for schools. It seamlessly combines curriculum planning, pupil assessment, progress analysis and parental engagement in one place. It supports teaching and learning best practice, whilst reducing workload so teachers have more time to focus on the development of their pupils. Our core ideology is that all students should reach their full potential. The InfoMentor system is built on the latest educational research and practices to optimize pupil’s performances. Our company goal is to be one step ahead and we aim to achieve this in each of Mentor’s projects.

Mentor is the data processor of the data processed in the InfoMentor system. The data processor is the entity which processes personal data on the behalf of the data controller in accordance to specified instructions from the controller based on processing agreements. Mentor is therefore the data processor for schools and educational institutions which use the InfoMentor system. Educational institutions and schools using the system host all collected information and data.
InfoMentor is the data controller for processing personal data which is collected for the purpose of Mentor’s services offering, sales, or marketing. The data controller is one who determines the purpose and means of collecting personal data and has the responsibility to ensure that all data processing is carried out in accordance to current data protection regulations and that the data processing is based on valid legal grounds and professional standards.

In this privacy policy, Mentor ensures its commitment to the protection of personal data and privacy. This policy defines the objectives and general principles for Mentor’s privacy governance along with information on what data is collected, why it is collected, security measures guarding collected information, rights of data subjects, and how they can contact the company’s data protection officer.

1. Mentor’s policy for processing personal data

Mentor is dedicated to protecting privacy and confidentiality. All processing of personal data, whether Mentor is considered a data processor or a data controller, is conducted in accordance to current data protection regulations and based on valid legal grounds and professional data protection standards.

The company main emphasis include:

  • Privacy regulations are taken into account during program design, development and implementation.
  • Processing of personal information at InfoMentor requires that all necessary organizational and technical measures is taken into account in accordance to current laws and regulations.
  • Processing of data for a data controller is based on a valid contract that sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller.
  • The InfoMentor information system supports users’ obligations to comply with privacy regulations and the processing in the system offers adheres to the legitimate consent for data processing.
  • Providing InfoMentor’s customers with support, education, and advice on data privacy.
  • Ensure the appropriate technical and organizational measures are maintained and reviewed on a regular basis.
  • As the data controller, InfoMentor is able to meet the requirements of data subjects’ rights in accordance to current privacy regulations and, where InfoMentor is the data processor, InfoMentor is able to assist the data controller in fulfilling their privacy requirements towards the data subjects.

 

Responsibility, confidentiality and respect for the rights and freedom of data subjects and their privacy is the foundation of Mentor’s approach to processing and handling of personal data.

2. Processing personal data in the InfoMentor information system

Mentor is the data processor of the InfoMentor information system. All processing of personal information in the interest of the data controller is made in accordance to processing contracts which sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller. Mentor, as a data processor hosts the InfoMentor system, which includes the retention of the data which the system stores.

Mentor does not record any personal information into the InfoMentor system such as information about students, family members or employees and it does not collect any information from the InfoMentor system for the means of processing information its own benefit.

The data controllers of InfoMentor are in most cases preschools, elementary schools, colleges, or other educational institutions. In the InfoMentor system, it is possible to record various information about students and their family members, such as names, addresses, telephone numbers and various information related to the education and schooling of students. It is also possible to enter necessary information about employees. Data controllers (Employees of the educational institutions) record personal information into the InfoMentor system and are responsible for the information contained therein. The data controller needs to ensure that records are relevant, fair, transparent, and that data processing is carefully made in accordance to current data privacy laws and regulations. Administrators of the educational institutions control who has access to the InfoMentor information system. Decisions regarding storing users’ information, retention periods, backup and storage procedures, sending and erasure of personal data concerning the students, parents and employees, resides with the controllers (educational institutions).

Mentor does not share or provide any information from the InfoMentor system unless a formal request is made from the data controller or there are clear legal grounds in place.

The deletion of data in the InfoMentor system is only performed when there is a formal request from the data controller. When there are no longer any substantive or valid reason for the retention of data, the data controller should inform InfoMentor of which electronic data should be discarded. When data is discarded, it is not possible to recover. Erasure of personal data is subject to defined operating procedures which Mentor has specified.

As Mentor has the responsibility of operating and servicing of the InfoMentor system, there are instances where it may be necessary for Mentor’s employees to access the system while assisting users or repairing the system. There are strict operating procedures in place at Mentor regarding which employees can perform such services and they are only ever conducted when a formal request is available from the data controller. All in-system actions of Mentor’s employees are logged and traceable back to individuals. All employees of the company are bound by confidentiality. See chapter 5 for further information of technical and organizational security measures.

3. Processing personal data for the purpose of servicing users of the InfoMentor information system

Mentor is the data controller for the processing of general personal information which the company collects and stores in connection to customer service and consultation to the customers of the InfoMentor information system.

Data controllers contact information

Data controllers (Educational institutions) regularly send Mentor information regarding contact persons to the InfoMentor services team. Contact information Mentor receives contains names and e-mail addresses of the contact person (data subject).

Customer service and system user consultation

Mentor records this information in order to send information, instructions and other content relating to the InfoMentor system to the contact persons.

The data controller notifies Mentor if there are any changes to the contact persons and if there are changes to the contact persons, the former contact information, e-mail, and name is discarded.

When a user in the InfoMentor system requests services and advice by e-mail or phone, a service ticket is created and linked to the user (when they ask for assistance from a programmer or a member of the InfoMentor support team). This is done in order to contact the person for the purpose of the service ticket and also to provide an overview and record over the services rendered to users and customers. Personal data collected from this process is stored in an access controlled and restricted customer relations system. Service tickets are otherwise not stored or registered in a personally identifiable way.

The personal information we may collect are:

  • Name
  • Username (National identification number/social security number)
  • Job title
  • School or institution
  • E-mail address
  • Phone number

Mentor does not share any information that the company collects due to services rendered to users of the InfoMentor system to third parties. A formal request can be made to erase any information from the customer relations system. See chapter 5 for further information on technical and organizational security measures.

4. Processing personal data for the purpose of general service provision, sales or marketing of Mentor

Mentor is responsible for the processing of general personal information that the company collects and records in connection with various services, sales and marketing. This may include mailing lists, registration of system training-courses, requesting notifications from information systems, participation in a specialists groups on social media or participation in pedagogical evaluation on the InfoMentor’s website. Mentor collects this information through its websites www.infomentor.com and www.socratess.com.

The purpose of collecting this personal information is to enable Mentor to communicate with and to serve customers. The collection of information is also to be able to share information to interested parties regarding the company’s operations and for marketing activities.

All data processing for this purpose is built on an informed consent of the data subject.

The personal information we may collect are:

  • Name, e-mail address, job title and educational institution of the person who is interested in being on InfoMentor’s mailing list.
  • Name and e-mail address of an individual who is interested in an introduction to the InfoMentor system.
  • Name, e-mail address, job title and educational institution for those who register for a course / conference or other event at InfoMentor.
  • Name, e-mail address, educational institution and city of a person who answers questions related to school evaluations on the website socratess.com.

All personal information collected by Mentor is stored in an access controlled customer service system or in a closed electronic storage area. See chapter 5 for further information on technical and organizational security measures.

Personal data collected by the web site www.socratess.com is erased annually, unless the data subject request that the information is erased earlier. Personal data collected for mailing lists is erased at the request of the data subject, and the data subject can unsubscribe by clicking a link on the bottom of the newsletter. Data subjects may also send an e-mail request to support@infomentor.co.uk to request to be removed from the mailing list or request erasing of personal information for other registrations at Mentor. All personal information about the data subject is consequently erased from the system.

Mentor does not share or transfer any personal information to third parties that the company has collected and recorded for sales, service or marketing purposes to third parties.

Mentor uses Cookies in its websites www.infomentor.com and www.socratess.com. No personal information is collected about the website’s users and no personal information is transferred. Cookies are small text files which will typically be placed on a computer or internet-enabled device whenever the website is visited. Although most internet browsers automatically accept cookies, settings can be changed to block cookies. Further information in Mentors Cookie policy.

5. Security measures

Mentor, whether the company is considered as a data controller or data processor, is strongly committed to processing personal data with the appropriate security measures to ensure its protection.

Mentor operates according to the requirements of ISO-27001 and ISO-9001 information security standards. All security measures that are taken are based on data classification and data process impact assessments. The company has a written security policy and conducts a regular data processing risk assessment. A regular review and assessment of the effectiveness of technical and organizational security measures for ensuring the security of all processing of data is conducted and is led by Mentor’s Chief Operating Officer.

Mentor’s security team comprises of employees in each office. The team oversees the development and implementation of security measures and meets weekly to review issues at hand.

All information concerning InfoMentor’s users is handled with the utmost caution to ensure that information is not lost or ends up in the hands of unauthorized persons.

5.1.        InfoMentor employees access to information

Employee access rights to the InfoMentor system is based on their job requirements and role within the company by the least privilege.

Access to information regarding the users of the InfoMentor system is controlled and segregated by lines of duty, and employees should only perform transactions in the systems which are necessary for them to complete their job functions. Mentor’s employees must be able to justify all in-system transactions if a review of their transaction log were to be done. The InfoMentor system has built in logs which can track all actions an employee makes within the system to ensure traceability of actions.

Access rights and supervision of employees is in accordance to Mentor’s defined operating procedures on information security. Managers for each of Mentor’s departments conduct regular reviews of their employee’s access privileges. The Chief Information Security Officer is responsible for ensuring the employees system access is in accordance to their job function. If an employee leaves the company or is terminated, all access privileges are to be revoked or removed.

5.2.        Employee confidentiality and non-disclosure

All of Mentor’s employees sign a non-disclosure agreement to ensure confidentiality of information. Employees are obligated to keep all information they may come across during their work regarding the company, its customers or the users of InfoMentor system, confidential. Mentor’s employees are required to perform this obligation dutifully in order to prevent the possible damage to the interest of the data subjects in the InfoMentor system. Employee confidentiality and non-disclosure is retained even after the employee has resigned from his job with Mentor.

5.3.        Response to personal data breach

Mentor, whether in the capacity of a data controller or a data processor, emphasizes clear working procedures in response to possible data breach involving personal information.

Mentor as a data processor will notify the data controller, the school administration and contact person immediately if a security breach occurs. The controller shall then notify the Data Protection Authority and the data subjects as applicable in accordance to current data protection regulation. Mentor will assist the data controller as necessary in this process. Mentor documents the breach and evaluates its effects and remedial action taken.

Mentor as a data controller will notify the Data Protection Authority as applicable to laws and regulation. Effects and risk to the rights and freedoms of the data subjects will be evaluated and if the personal data reach is likely to result in a high risk, Mentor shall communicate the personal data breach, its effect and remedial action taken to the data subject. Mentor documents and evaluates the breach, its effects and necessary remedial actions.

6. Rights of data subjects in regard to personal data processing

Mentor as a data processor is highly committed to ensuring the InfoMentor information system is designed and developed with the data subject’s rights in mind and that the system is capable of assisting the data controller in ensuring compliance with the obligations towards the data subjects.

Data subjects cannot approach Mentor directly regarding personal information that is stored in the InfoMentor system as the information that the system retains is the responsibility of the educational institutions (the data controllers). In such cases, the data subject needs to go to the corresponding educational institution with the request of removing personal information.

As the data controller, Mentor is committed to ensuring that the rights of the data subjects relating to their stored personal information complies to applicable privacy laws and regulations.

All data subjects from whom Mentor collects personal information has the right to know what information that is collected and stored about them with the company. This privacy policy has identified what information is collected by Mentor and for what purpose. Data subjects can request access to their personal information. If a data subject believes the personal information Mentor collects is incorrect, they may ask us to correct any inaccuracies in the personal information. Data subjects also have the right to object to data processing or have their personal information erased or deleted. Data subjects can make a request or exercise these rights by contacting Mentor’s data protection officer (dpo@infomentor.is).

When processing personal data is based on the data subject’s consent, data subjects can at any time withdraw their consent.

If a data subject believes that the processing of personal information at Mentor in any case does not comply with applicable data protection laws or regulations and does not adhere to safe data processing methods, they can send a complaint or notice to our data protection officer (dpo@infomentor.is).

Everybody has the right to seek out the Data Protection Authority (the Information Comissioners Office, or ICO) if they believe their privacy rights have been infringed upon or if they believe privacy laws have been broken. Information regarding complaints and notifications to the Data Protection Agency can be found on their website: https://ico.org.uk/.

7. Changes and revision of Mentor’s Privacy Policy

All decisions regarding processing of personal data are made by Mentor’s management team and the board of directors, with the assistance and guidance of our data protection officer.

Please note that this policy will be regularly reviewed and may change accordingly, as to reflect Mentor’s business operation and handling of personal data at any given time.

This Privacy policy is published on Mentor’s website, www.infomentor.com and the website www.socratess.com. The Privacy Policy can also be made available to users by emailing support@infomentor.co.uk.

8. Data protection officer – further information

If you have any concerns, comments or requests for further information regarding the processing of personal information at Mentor, please contact our data protection officer.
Gunnur Líf Gunnarsdóttir – dpo@infomentor.is

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